IMO Chemical Regulations January 2013
Revised MARPOL Annex V (IMO Chemical Regulations January 2013) sets new regulatory requirements regarding the disposal of garbage from ships and will come into force on 1 January 2013.
The new amendments prohibit the disposal of almost all kinds of garbage at sea with the exemption under specific requirements of food waste, animal carcasses, cargo residues contained in wash water and environmental friendly cleaning agents. As a result of these regulations more and more ships will dispose their ship-generated waste to reception facilities ashore. MARPOL Annex V applies to all ships.
Generally, discharge is restricted to food wastes, identified cargo residues, animal carcasses, and identified cleaning agents and additives in washwater which are not harmful to the marine environment. Garbage discharge regulations do not apply when the discharge of garbage from a ship was a necessary action for the purpose of securing the safety of a ship and those on board or saving life at sea. In such cases an entry should be made in the Garbage Record Book, or in the ship’s official log-book for ships of less than 400 gross tonnage.
According to revised MARPOL Annex V (IMO Chemical Regulations January 2013) shipboard generated garbage is to be grouped into the following categories:
- Plastics – Garbage that consists of or includes plastic in any form, including synthetic ropes, synthetic fishing nets, plastic garbage bags and incinerator ashes from plastic products. Garbage under this category is prohibited to be discharged at sea.
- Food wastes – Spoiled or unspoiled food substances. Food wastes may be discharged at sea under specific circumstances/requirements (refer to the simplified overview of the discharge provisions of the revised MARPOL Annex V developed by IMO).
- Domestic Wastes – Garbage generated mainly in the accommodation spaces on board the ship (e.g. drinking bottles, papers, cardboard etc). Garbage under this category is prohibited to be discharged at sea.
- Cooking Oil – Edible oil or animal fat used for the preparation or cooking of food. Garbage under this category is prohibited to be discharged at sea.
- Incinerator ashes – Ash and clinkers resulting from shipboard incinerators used for the incineration of garbage. Garbage under this category is prohibited to be discharged at sea.
- Operational wastes – Solid wastes (including slurries) that are collected on board during normal maintenance or operations of a ship, or used for cargo stowage and handling. Operational wastes also includes cleaning agents and additives contained in cargo hold and external wash water that may be harmful to the aquatic environment. Operational wastes does not include grey water, bilge water, or other similar discharges essential to the operation of a ship (boiler/economizer blowdown, gas turbine washwater, machinery wastewater etc). Garbage under this category is prohibited to be discharged at sea.
- Cargo residues – Remnants of any cargo which remain on the deck or in holds following loading or unloading. This category does not include cargo dust remaining on the deck after sweeping or dust on the external surfaces of the ship. Such garbage may be discharged at sea under specific circumstances/requirements (refer to the simplified overview of the discharge provisions of the revised MARPOL Annex V developed by IMO). It is essential to remember that besides other requirements (e.g. distance from shore) cargo residues in order to be discharged at sea they should not be harmful to the marine environment. Cargo residues which are considered harmful to the marine environment are classified according to the criteria of the United Nations Globally Harmonized System for Classification and Labelling of Chemicals (UN GHS) meeting parameters such as: acute aquatic toxicity category 1, chronic aquatic toxicity category, carcinogenicity, mutagenicity, reproductive toxicity etc
- Animal Carcasses – Bodies of any animals that are carried on board as cargo and that die or are euthanized during the voyage. Discharge of such wastes permitted at sea under specific circumstances/requirements (refer to the simplified overview of the discharge provisions of the revised MARPOL Annex V developed by IMO).
- Fishing Gear – Physical device that may be placed on or in the water or on the sea-bed with the intended purpose of capturing marine or fresh water organisms. Garbage under this category is prohibited to be discharged at sea.
These new categories represent the categories to be used for record purposes in the Garbage Record Book. The superseded MARPOL Annex V (IMO Chemical Regulations January 2013 defined six categories whereas the revised annex defines nine.
Regarding the cleaning agents mentioned above, a cleaning agent or additive is considered as not harmful for the marine environment when:
- The Chemical used is not a “harmful substance” in accordance with the criteria in MARPOL Annex III. This means substances identified by criteria such as Acute (short-term) aquatic hazard, rapidly or non-rapidly degradable substances for which there are adequate chronic toxicity data available and substances for which adequate chronic toxicity data are not available. Tables containing criteria values for the identification of harmful substances as per revised MARPOL Annex III can be found HERE. Mentioned criteria are based on those developed by the United Nations Globally Harmonized System of Classification and Labelling of Chemicals (GHS), as amended. The GHS can be found HERE.
- The Chemical used does not contain any components which are known to be carcinogenic, mutagenic or reprotoxic (CMR). In order to identify such components the GESAMP list can be used.
To sum up the above, when a ship is discharging chemicals agents from hold wash water to the sea and records such action to the Garbage Record Book then the ship should be able at any time to provide evidence that the cleaning agent or additive used was not harmful to the environment. Such evidence may be provided by the chemicals’ manufacturer under the form of signed and dated statements providing information that the chemical/product meets the criteria for not being harmful to the marine environment. This might form part of a Safety Data Sheet or be a stand-alone document.
Of course the same applies for the cargo that was previously stored within the hold, meaning that hold wash water and cargo residues cannot be discharged if the previous cargo contained within the ship’s hold was not declared as not being harmful to the marine environment according to Section 4.2 of the International Maritime Solid Bulk Cargoes (IMSBC) Code.
In case garbage is mixed with or contaminated by other garbage which have different discharge requirements, the more stringent requirements shall apply. For example, if a vessel is sailing within a special area and has mixed comminuted food waste with food waste that is no comminuted then according to the revised MARPOL Annex V regulations the vessel should not discharge the food waste mixture to the sea.
A simplified overview of the discharge provisions of the revised MARPOL Annex V (IMO Chemical Regulations January 2013) which will enter into force on 1 January 2013 has been developed by the IMO and is presented here below.
1 These substances must not be harmful to the marine environment.
2 Discharge shall only be allowed if: (a) both the port of departure and the next port of destination are within the special area and the ship will not transit outside the special area between these ports (regulation 18.104.22.168); and (b) if no adequate reception facilities are available at those ports (regulation 22.214.171.124)
It is likely that shipboard garbage destined to be sent to a port waste reception facility will need to be segregated. The requirements for the port concerned should be sought and followed in this respect. Given that some ports may not be able to receive and process all types of waste, the garbage processing capability of the port should be checked prior to arrival.
Every ship of 12 m or more in length overall and fixed or floating platforms shall display placards which notify/inform the crew and the passengers regarding the discharge requirements that apply to the ship. The placards shall be written in the working language of the ship’s crew and in English or French or Spanish (this requirement remains the same with the one of the superseded regulation of MARPOL Annex V)
Every ship of 100 gross tonnage (instead of 400 GT required by the superseded MARPOL Annex V) and above, and every ship which is certified to carry 15 or more persons, shall carry a garbage management plan (based on IMO Guidelines MEPC.220(63) and in working language of the crew) containing procedures on
- garbage minimization
- garbage collection
- garbage storage
- garbage processing
- garbage disposal
- equipment used onboard for handling of garbage
- the designation of the person or persons in charge for implementing the Garbage Management Plan
In addition to the Garbage Management Plan every ship of 400 gross tonnage and above and every ship which is certified to carry 15 or more persons engaged in voyages to ports which are under the jurisdiction of another Party to the Convention should maintain a Garbage Record Book in the form specified in the appendix of the revised Annex. The requirement to maintain a Garbage Record Book remains the same with the superseded MARPOL Annex V with the difference that the layout of the form which will record the garbage discharges is different from the superseded one.
Apart from the above which are requirements of the revised MARPOL Annex V (IMO Chemical Regulations January 2013), in order to enhance the implementation of the onboard Garbage Management Plan and to exercise better garbage handling procedures in overall, meaning from the generation of the garbage onboard to the appropriate disposal of them, ships’ crews and agents could make use of IMO’s developed standard format for the advance notification of waste delivery to port reception facilities as defined in IMO Circular MEPC.1/Circ.644.
In addition, where a ships’ Master or agent finds reception facilities in a port inadequate (for example the facility required is not available or is inconveniently located, has unreasonable charges and/or cause undue delay) the Master should forward the information contained in MEPC.1/Circ.469/Rev.1, together with any supporting documentation, to the Administration of the flag State and, if possible, to the competent Authorities in the port State.
Finally, following a ships’ use of port reception facilities the ships’ crews and agents should encourage waste reception facilities service providers to use the IMO standard format for the waste delivery receipt as outlined in MEPC.1/Circ.645
For further reading regarding Garbage Management and revised MARPOL Annex V requirements you can also refer to the following:
- Revised MARPOL Annex V MEPC.201(62)
- Guidelines for the implementation of MARPOL Annex V MEPC.219(63)
- Guidelines for the development of Garbage Management Plans MEPC.220(63)
- Guide to good practice for port reception facilities providers and users MEPC.1/Circ.671
- Advanced notification form for waste delivery to port reception facilities MEPC.1/Circ.644
- Reporting alleged inadequacies of port reception facilities MEPC.1/Circ.469/Rev.1
- Waste delivery receipt IMO format MEPC.1/Circ.645
IMO Approvals of Tank Cleaning Chemicals
Aquamarine Products Approved 16th February, 2011
The IMO has changed the Approval of Tank Cleaning Additives regulations and process, in order to cut down on the number of chemicals on their list of approved tank cleaning products. http://www.imo.org Continue reading →